Third Circuit Holds Contribution Action Accrues on Entry of Consent Order but Doesn’t Decide Which Limitations Period Applies

November 26, 2019
Shoshana (Suzanne Ilene) Schiller
MGKF Litigation Blog

Sometimes a movie can solve one mystery but hold off answering others, leaving viewers eager for the sequel. Legal opinions can be the same, as is the Third Circuit’s opinion in Cranbury Brick Yard, LLC v. United States, No. 18-3287 (3rd Cir. Nov. 22, 2019). After holding that the limitations period for a contribution action accrues from the date of entry into a non-judicial settlement and order on consent, the Court then sidesteps the issue of exactly what limitations period applies.

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